ACO Comments on the Proposed Provincial Planning Statement 2024

AUTHOR: ACO

DATE: May 13, 2024

Architectural Conservancy Ontario (ACO) appreciates the considerable work thus far on a revised Provincial Planning Statement and has three suggestions to improve this important document

NEWS DESCRIPTION:

1. Definition of protected heritage property: Correct a fundamental omission in section 8.

This definition, which is critical for PPS 2024, Policy 4.6 Cultural Heritage and Archaeology, must include all property protected under the Ontario Heritage Act. The following categories of property should be added to the list in the definition:Property subject to a notice of intention to designate in accordance with section 29(1.1) and subject to the limitations in section 29(1.2) of the Ontario Heritage Act;

• Property subject to a by-law designating an area as a heritage conservation study area in accordance with section 40.1 (1) of the Ontario Heritage Act; and
• Non-designated [i.e. listed] property of cultural heritage value or interest included on the municipal register in accordance with section 27(3) of the Ontario Heritage Act.

ACO is supportive of the goals of this review, as summarized in the five policy themes outlined in the ERO posting. We share the province's interests in generating an appropriate housing supply, balancing housing with resources, and providing infrastructure to support development. We have long promoted a solution which meets all these objectives: the adaptive reuse/renovation of existing and heritage buildings, buildings that are already serviced by existing infrastructure.

Two additions to the Provincial Planning Statement are needed to support this solution.

2. Policy 2.1 Planning for People and Homes

A further sub-clause needs to be added to section 4:
c) shall identify and encourage the redevelopment of existing buildings and other structures as housing. This proposed addition would ensure that section 4 does not conflict with or undermine Policy 2.2 Housing, section 1, clause b), sub-clause 2.

A huge percentage of existing buildings are empty (e.g. approximately 25% of office space in some Ontario cities following the effects of COVID 19) so the potential to adaptively reuse existing buildings and other structures (including, but not limited to shopping malls, plazas, and office buildings) should be taken into consideration by planning authorities when maintaining the ability to meet projected requirements for housing. The PPS should clearly recognize and acknowledge that the renovation sector (not the new construction sector) is now the predominant wing of the development industry employing tens of thousands of Ontarians.

For environmental and climate change reasons the most sustainable options are those that keep, fix and re-use our older buildings. One has only to consider the greater carbon/greenhouse gas impacts of new construction (plus the new public infrastructure often required to service it) compared to the lower carbon footprint for the re-use of current, already serviced buildings. The province should place greater emphasis/priority on approaches that upgrade and re-use Ontario's existing building stock specifically for housing. The proposed Provincial Planning Statement needs to make this clear.

3. Policy 2.9 Energy Conservation, Air Quality and Climate Change: In addition to the recommendation above for Policy 2.1, we recommend adding the following underlined wording to Policy 2.9, section 1, clause e): Take into consideration any additional approaches, such as determining whether to demolish or retain, and potentially adaptively re-use, existing buildings and other structures, that help reduce green house gas emissions and build community resilience to the impacts of a changing climate.